In an article for Bloomberg Law, Manatt Partner Matthew Williamson examined California Department of Toxic Substances Control’s (DTSC) novel permitting and enforcement scheme impacting all permitted hazardous waste facilities in the state as the program enters year three. Williamson explained that problems with the state’s Violations Scoring Procedure (VSP) range from the inclusion of disputed violations in facilities’ scores to delays that have beleaguered DTSC’s issuance and administrative review of scores. “In addition, a number of facilities have sued DTSC, challenging their VSP score or challenging the regulations as a whole,” Williamson stated. “Efforts are now underway to make the system more equitable.”
Bloomberg Law subscribers can read the full article here.